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In the Manchester Arena Inquiry a Public Inquiry Into IN THE MANCHESTER ARENA INQUIRY A PUBLIC INQUIRY INTO THE DEATHS OF 22 PEOPLE THAT LOST THEIR LIVES IN THE ATTACK AT THE MANCHESTER ARENA ON 22ND MAY 2017 __________________________________________________ OPENING STATEMENT ON BEHALF OF ROBERT BOYLE, PAUL HETT AND PAUL PRICE __________________________________________________ COUNSEL: Guy Gozem Q.C. Austin Welch Leila Ghahhary Lincoln House Chambers Tower 12, Spinningfields, Manchester M3 3BZ Tel: 0161 832 5701 SOLICITORS: Ms Erin Shoesmith Ms Priscilla Addo-Quaye Addleshaw Goddard LLP One St Peter’s Square Manchester M2 3DE Tel: 0161 934 6000 INQ035477/1 IN THE MANCHESTER ARENA INQUIRY A PUBLIC INQUIRY INTO THE DEATHS OF 22 PEOPLE THAT LOST THEIR LIVES IN THE ATTACK AT THE MANCHESTER ARENA ON 22ND MAY 2017 __________________________________________________ WRITTEN SUBMISSIONS ON BEHALF OF ROBERT BOYLE, PAUL HETT AND PAUL PRICE __________________________________________________ Introduction 1. This opening statement is made on behalf of Robert Boyle, the father of Courtney Boyle, Paul Hett, the father of Martyn Hett, and Paul Price, the partner of Elaine McIver. 2. At shortly before 10.30pm on Monday 22nd May 2017, Courtney Boyle, Martyn Hett and Elaine McIver all found themselves in the City Room foyer of the Manchester Arena. The City Room was a meeting place. Martyn Hett had attended the concert and was waiting for friends before going on to another venue; he was celebrating as he was due to be travelling to America the following Wednesday for a 2 month holiday. Courtney Boyle was waiting to pick up her younger sister Nicole, aged 15, who had been to the concert. Elaine McIver, who was in company with her partner Paul Price, was waiting to pick up Paul’s daughter Gabrielle, aged 13, and her friend Macie, aged 14, who had also been to the concert. INQ035477/2 3. Courtney, Martyn and Elaine did not know one another, they had never met and had never spoken with one another. However, they did share one thing in common that they also shared with other members of the public who were waiting for their loved ones in the City Rooms on 22nd May 2017 or who were leaving the concert; they believed that the area was safe and they believed that they were safe. Tragically, they were all mistaken. 4. The Chairman has indicated that he would be assisted by statements from the family teams that identify topics within the terms of reference that are of specific interest to us and to explain why those topics will be our focus during the course of the oral hearings. We present this statement as the fourth of the four family teams. Our aims are complementary to the other teams, our goals are shared. We have cooperated fully with the other teams and with the Inquiry Legal Team and will continue to do so. In this opening statement we do not intend to simply repeat those matters that have been raised by the other family teams. However there are two primary questions that Robert Boyle, Paul Hett and Paul Price have and which they hope that your Inquiry will be able to answer: (i) How was it that Salman Abedi was allowed to be in a position whereby he could detonate a bomb in the City Room at 10.32 pm on 22 May 2017? (ii) Could the tragic events of 22 May 2017 and the deaths of their loved ones have been avoided? Background 5. We have chosen our words in relation to the first question carefully and deliberately. The disclosure of material by the Inquiry Legal Team to the families and other core participants over the past 18 months, that will be presented to and considered by the Chairman during the course of this Inquiry, has revealed a series of mistakes, errors and missed opportunities by state agencies, corporate bodies and individuals charged with ensuring the safety of members of the public generally, attendees at events in the Arena and people attending the City Room itself. INQ035477/3 6. The attack at the Manchester Arena was, tragically, not exceptional nor should it have been unforeseeable. The actions of all Core Participants in this Inquiry, but particularly those involved in security, both at a national level and in relation to the Arena and Victoria Station complex specifically, must be viewed in the proper context of the threat posed by terrorism on and before 22nd May 2017. 7. In 2016, there had been 16 Islamist terrorist attacks in Europe. The multi-sited attacks in Paris, which included the attack at a concert at the Bataclan theatre had occurred only 18 months before the Manchester attack. Prior to 22nd May there had already been 5 Islamist terrorist attacks in Europe in 2017, and only 2 months before, on 22nd March 2017, 5 people were killed and 50 injured when an Islamist terrorist drove into pedestrians on Westminster Bridge and stabbed an unarmed police officer. 8. In response to the March 2017 Westminster attack, Prime Minister Teresa May gave a statement to Parliament. She said as follows: “We know the threat from Islamist terrorism is very real. But while the public should remain utterly vigilant they should not – and will not – be cowed by this threat. As Acting Deputy Commissioner Rowley has made clear, we are stepping up policing to protect communities across the country and to reassure the public. And as a precautionary measure, this will mean increasing the number of patrols in cities across the country with more police and more armed police on the streets. But the greatest response lies not in the words of politicians, but in the everyday actions of ordinary people. For beyond these walls today – in scenes repeated in towns and cities across the country – millions of people are going about their days and getting on with their lives. The streets are as busy as ever. The offices full. The coffee shops and cafes bustling. INQ035477/4 It is in these actions – millions of acts of normality – that we find the best response to terrorism. A response that denies our enemies their victory. That refuses to let them win. That shows we will never give in.” 9. On the same day NaCTSO provided a security update in the following terms: Following the tragic incident on Westminster Bridge and at the Palace of Westminster on 22 March 2017 it is important that the police, security stance and the private sector are joined up. To ensure this NaCTSO recommend businesses consider some protective security tactics to aid their security, whilst remembering that the threat level remains at ‘SEVERE’. The attack incorporated multiple methodologies - as such no one security element will wholly mitigate such attacks. We understand that people responsible for building security have differing priorities, some being responsible for large iconic sites and others for small businesses, but the message remains the same - effective security and effective communities defeat terrorism We know that terrorists will undertake hostile reconnaissance ahead of conducting an attack and increased vigilance by staff and the creation of a hostile environment combats such hostile reconnaissance. You should refresh the knowledge of staff that have received Project Griffin and Project Argus training and deploy staff who have received training in behavioural detection (where you have them). Staff should be encouraged to proactively challenge visitors, vehicles, and anything out of place. It is important that you review your security plans; consider the following options from the National Stakeholder Menu of Options, particularly around crowded places, night- time economy, and iconic sites. It is recommended that businesses look at the full menu and consider any other options that suit your premises or organisation. INQ035477/5 10. The threat level remained at severe, meaning that an attack was highly likely. Yet Courtney Boyle, Martyn Hett and Elaine McIver fulfilled their part of the bargain in responding to that threat. They went about their daily lives as before. They engaged in acts of normality, and there can be nothing more normal than a young man celebrating with his friends by going to a pop concert or parents and older siblings waiting in an area with hundreds of others to meet and take home their family members, teenage girls, who had attended the pop concert. Term of Reference 4 – The Security Arrangements Within and Outside the Arena 11. Robert Boyle, Paul Hett and Paul Price now believe that whilst their family members fulfilled their part of the bargain, others did not. The first topics within the terms of reference that our clients are most concerned with, are those concerning the security arrangements within and outside the Arena – term of reference 4. This matter has become the cause of anguish and distress for our clients because of what they now know in relation to the security measures that were employed at the Arena and the events of the evening of 22nd May 2017. These concerns have given rise to a number of questions that our clients hope will be answered by this Inquiry. There are 5 matters that have caused our clients particular concern and that have meant that the matters listed in terms of reference 4 are, for them, a priority. 12. Firstly, it is now known that Salman Abedi alighted the Metrolink at Victoria Station at just after 8.30pm. He was carrying a large rucksack containing the explosive device he would later detonate. He spent the next 2 hours within the Victoria Station complex, entering the City Room for the first time at shortly after ten minutes to 9pm. He remained there for 19 minutes. He then wandered through the station and spent time waiting at the Metrolink platform before, again, returning to the City Room at 9:33pm where he remained until the bomb was detonated, just under 1 hour later.
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